Letter to Lisa Jackson, VP of Environmental Affairs at Apple and former administrator of the US Environmental Protection Agency

Credit: Eric Vance, EPA photographer

On June 10, 2014, more than 80 environmental and human rights organizations, socially responsible investment firms, and occupational health professionals
sent a letter to Lisa Jackson, VP of Environmental Affairs at Apple, calling on the company to remove hazardous chemicals, such as benzene, from its supplier factories in an effort to protect workers from grave illnesses.

Jackson is the former administrator of the US Environmental Protection Agency. At the EPA, Jackson monitored benzene levels in the water and air to ensure no one was exposed to dangerous levels of this known human carcinogen. The letter calls on Jackson to make worker health and safety a priority in her second year at Apple.

Letter Text

Dear Ms. Jackson:

Congratulations on the one-year anniversary of your new position at Apple. We are pleased to see that Apple has elevated environmental initiatives to the VP level. We are also pleased to see you at the helm of these efforts, given your experience regulating environmental issues in the US, including the four years you led the Environmental Protection Agency (EPA).

As a group of environmental and human rights organizations, socially responsible investment firms, and businesses, we write today to voice concerns we share for the workers who make and assemble Apple products. These young workers in your supplier factories run the risk of being exposed to high levels of toxic chemicals and suffering from grave diseases as a result. Since you are a chemical engineer and senior manager at Apple, we hope you will influence Apple to be the first major electronics brand to disclose and eliminate the most dangerous chemicals from your manufacturing processes and ensure better protections for workers who are exposed to chemicals.

Electronics manufacturing in China is a huge and evolving industry in which – despite laws to protect worker safety and corporate codes of conduct – workers are getting sick as a result of occupational exposure to dangerous chemicals. As you likely know, thousands of chemicals are used in the process of making electronics devices, including many chemicals known to be carcinogens, reproductive toxins, neurotoxins and others that are largely untested.

Best practices in electronics manufacturing would include a hierarchy of controls in which the most dangerous chemicals would be eliminated and/or substituted with safer alternatives. The workplace and processes would be designed in such a way as to increase airflow and remove chemical-exposure risk. High-quality safety training and protective equipment would be provided to all workers handling chemicals so they know what risks they are being exposed to and how to protect themselves.

Apple does not disclose a full list of the chemicals used in production, but two chemicals known to be used and of immediate concern include benzene and n-hexane, both of which have been linked to worker illness in Apple supplier factories. The WHO’s International Agency for Research on Cancer (IARC) classifies benzene in Group 1 as it is known to be carcinogenic to humans and the US EPA classifies benzene in Group A, as a known human carcinogen for all routes of exposure. Prolonged exposure to benzene can cause leukemia. N-hexane is a neurotoxin that can cause nerve damage. Both of these chemicals, and many others typically used in electronics manufacturing, have had serious effects on many workers, costing them their livelihoods or their lives. Another chemical we know to be of concern, due to its ubiquitous use in electronics manufacturing, is industrial alcohol, which is more dangerous than simple rubbing alcohol and contains 5-10% methanol. Without proper precautions, long-term exposure to this substance can cause nerve damage and blindness.

In the US, OSHA has set the permissible exposure limit (PEL) to airborne benzene in the workplace to no more than 1 ppm for no longer than eight hours, or 40 hours per week, while NIOSH actually recommends a lower limit of just .1 ppm. According to the Ban Benzene campaign, the permissible exposure level for benzene in China for an eight-hour day is set at 1.878 ppm, or roughly double the limit established by OSHA (or roughly 20 times the safer limit recommended by NIOSH). This is compounded by the fact that electronics workers in China work far more than 8 hours per day. Workers in Apple supplier factories have been known to work up to 12 hours per day, and average 60 hours or more per week (according to 2013 investigations by China Labor Watch and the Fair Labor Association). This means that, with overtime, workers in Apple’s supplier factories could potentially be exposed to roughly three times the legal permissible limits set for workers in the US.

However, a number of electronics factories fail to follow Chinese regulations, so the exposure limit could indeed be greater than three times that of US workers. In addition, as you know from your previous experience, the environmental exposure limits are orders of magnitude more health protective than OSHA’s PELs, since they are designed to protect vulnerable populations, especially women of child bearing age – which includes hundreds of thousands of female workers in Apple's supply chain.

In your corporate responsibility reports, there is no evidence that Apple tracks the ambient levels of benzene and other hazardous chemicals in its supplier factories. Nor is there evidence that Apple tracks incidences of worker illness or injury in these factories. Without this basic information, there is no way for Apple to know when, where, and how many workers are getting sick from chemical exposure. Additionally, without this information, there is no easy way to provide treatment to the workers who need it. Thus, workers are left to navigate the complicated and frequently corrupt healthcare system in China's special economic zones. China Labor Watch has also documented in 2013 that pre-job worker safety training at some of Apple’s major supplier factories has fallen far short of the legally required minimum of 24 hours – as low as 10 minutes in one factory – and that the PPE provided to workers has been inadequate.

Additionally, Apple has not provided any information about the resolution of outstanding worker chemical poisoning and serious injury compensation cases in your current and former first-tier suppliers, such as Wintek, Foxconn, Flextronics, and Pegatron.

As one of the biggest, most profitable, and most advanced high-tech companies in the world, Apple should have a sophisticated means of tracking chemicals used, chemical exposure levels, and worker health and safety issues in its supplier factories. Apple already has such a system in place for the monitoring of product quality in factories; the same standard should be applied to human health. Apple would settle for nothing less than this if these products were being assembled in the US. Apple and the industry can no longer get away with moving these abuses offshore.

The young workers in your supplier factories work long, hard hours in hopes of a better future for themselves and their families back home. They are putting their trust in their employers and the brands for which they produce that they will not be poisoned by simply showing up to work and breathing the air or using their hands. You can protect the estimated 1.5 million workers in your supply chain and all future workers by taking the following steps:

1. Eliminate Toxic Chemicals
We call on Apple to stop the use of the most dangerous, toxic chemicals in Apple supplier factories and replace them with safer alternatives.

Toxic chemicals now in use include carcinogens such as benzene, reproductive toxins such as toluene, and neurotoxins such as n-hexane. Apple must identify and publicly disclose all chemicals used in supplier factories and in all Apple products, eliminating and substituting the chemicals known to be harmful to human health. In situations where the danger of a chemical is unknown, Apple must require proper testing. Apple must provide adequate safety training and protective gear free of charge to workers and must protect worker safety and health with appropriate exposure monitoring, medical monitoring, and effective training and management systems.

2. Ensure Adequate Medical Treatment
We call on Apple to create a fund to pay for the treatment of workers who suffer illness or injury from on-the-job exposures and ensure that all workers injured while making Apple products receive adequate treatment. For workers struggling to access care, Apple and its supplier factories must institute a safe and rapid mechanism for workers to report illnesses. Apple should also create a system to ensure that sick workers do, in fact, receive sufficient medical care.

3. End Worker Abuse
We call on Apple and its suppliers to ensure worker rights and empowerment. To protect these rights, Apple and its supplier factories should fully implement the United Nations Guiding Principles on Business and Human Rights including the prevention, mitigation, and remediation of human rights abuses.

We believe that Apple is the consumer electronics company that will first be able to implement these reforms. We know this because over the years Apple has attempted to improve its corporate responsibility in response to consumer concern, Apple has the financial resources to make these changes, and Apple has unique leverage with suppliers and within the industry. Most importantly, this is achievable because ultimately you care about what your customers want. Apple customers, including the people in the organizations signing this letter, want to know their beloved devices do not contribute to worker harm. Additionally, Apple shareowners will benefit from these reforms by reducing Apple’s reputational risk.

Thank you for your consideration of this issue and we hope you will take immediate action on the concerns raised so as to ensure that Apple is a leader in the industry in protecting workers.